Centered Solutions, LLC
Privacy Policy
Last Updated: December 2, 2024.
This privacy notice describes the information we collect when you access or use our browser-based application, and related services (collectively our "Services") and how we use, disclose, and protect this information. It also tells you about rights and choices you may have with respect to how to get answers to questions you may have about our privacy practices.
Your access and use of our Services indicate your consent to the terms of this Policy and our Terms of Use.
Information We Collect
We collect information using our Services as described below.
We process personal data elements like name, phone number, address, and medication information necessary for prescription ordering and local processing in our in-pharmacy workflow package. The data is used mainly for ordering medications and printing patient labels that are adhered to specific medication containers. This data is stored on a local hosted server and shared with other on-site patient management software systems.
Information We Receive from Third Parties
In order to support your experience using our Services, we may also collect information about you from third party partners and combine it with other information we collect about you from either directly electronic or manually by pharmacy staff who subscribe to our Services.
How We Use Information
We may use the information we collect for various purposes, including:
Legal
We reserve the right to access, use, preserve, transfer, or disclose, at any time without notice to you, any information as reasonably necessary to: (1) comply with any applicable law, regulation, subpoena, or legal process, or respond to any governmental requests or regulatory investigation and to cooperate with law enforcement, if we believe such action is required or permitted by law; (2) enforce our this Policy or our Terms of Use, including investigating any potential violations; (3) protect the safety, integrity, rights, or security of our users, our Services or equipment, or any third party; or (4) detect, prevent, or otherwise address fraud, security, or technical issues related to our Services or those of our business partners.
Data Analysis
We may also perform data analyses (including anonymization of personal information).
Business Purposes
We may process personal information in connection with providing or improving our service, partnerships or vendor relationships.
Data Processor
Note that when we process personal information provided by our customers for our Services, we are a data processor, and we only process personal information on behalf and on the instruction of our customers, which are data collectors.
How We Disclose Information
We may disclose the information we collect, including in the following ways:
Affiliates Partners
We may share your information with any members of our group, which includes our affiliates, subsidiaries, and branch offices, to which it is reasonably necessary or desirable for us to disclose your information in order to carry out the above-mentioned information processing purposes.
Business Transfers
We may choose to buy or sell assets and may share and/or transfer your information in connection with the evaluation of and entry in to such transactions. Also, if our company (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your information could be one of the assets transferred to or acquired by a third party.
Legal/Protection
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply this Policy or our Terms of Use and other agreements; or protect the rights, property, or safety of Centered Solutions, our employees, our users, or others.
Aggregate Data
We may de-identify your information and process and share it in an anonymous and aggregated form for purposes in addition to those described above. For example, we may share aggregate reports about business metrics.
Transborder Transfer
We may transfer or disclose personal information to recipients in countries outside of your country, including the United States, where we are headquartered. These countries may not have the same data protection laws as the country in which data may have been provided. When we transfer or disclose your personal information to other countries, we will protect that information as described in this Privacy Notice. We have certified to the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) Principles to provide adequate safeguards for the transfer of personal information to the United States from the European Economic Area ("EEA"). For more information, please see Centered Solutions' Data Privacy Framework Principles below.
Security
We are committed to protecting your information. We seek to use reasonable organizational, technical, and administrative measures to protect information within our organization. We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it or when you request their deletion.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of our servers has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact Us section below.
Updates to this Policy
From time to time we may, in our discretion, make changes to this Policy. The Last Updated date at the top of this page indicates when this Privacy Notice was last revised. If we make material changes, we may notify you through the Services, email or other communication. We encourage you to read this Privacy Policies periodically to stay up to date about our privacy practices and principles. Your continued use of our Services after we have updated this Privacy Policy constitutes your acceptance of the changes.
Contact Us
If you have questions about this Policy, please contact us.
Centered Solutions, L.L.C.
175 1st Street South, Unit 704
St. Petersburg, FL 33701
privacy@centeredsolutions.com
Data Privacy Framework Principles
Centered Solutions, LLC. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU and UK individuals and Swiss individuals, as set forth by the U.S. Department of Commerce. Centered Solutions has certified with the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S, and the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit www.dataprivacyframework.gov.
These Data Privacy Framework Principles supplements our Privacy Notice above. Capitalized terms used in this Data Privacy Framework Principles have meaning given to them by our Privacy Notice, unless specifically defined in the Data Privacy Framework Principles. The Data Privacy Framework Principles apply to Centered Solutions, which is subject to the investigatory and enforcement powers of the Federal Trade Commission.
How We Obtain Personal Information
We obtain and process Personal Information in different capacities within the European Economic Area ("EEA") physical locations. As a data processor, we process, and host Personal Information obtained from our customers when providing our services to our pharmacy-based customers. In that context, we only process Personal Information on behalf and on the instructions of our customers, which are data processing in order to order medications for future use. Also, as a workflow processor, we collect and process Personal Information directly from our customer and or through electronic information with Pharmacy Management system, such that patient orders can be correlated and print Personal information so that our customer can print and apply labels onto medication containers. We commit to subject to the Principles all Personal Information received from the EEA in reliance on the Frameworks (which includes both types of activities).
Personal Information Received from the European Economic Area
We may receive from the EEA some or all of the information listed in our Privacy Notice. Some of that information may qualify as "personal information" or "personal data" (collectively, "Personal Information") as defined in the Frameworks.
Data Integrity and Purpose Limitation
We may use the Personal Information we receive from the EEA for the purposes set forth in our Privacy Notice or as you may otherwise be notified. We take reasonable steps to ensure that the Personal Information we process is relevant and reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. We will adhere to the Principles for as long as we retain the Personal Information collected under the Frameworks.
When we process Personal Information on behalf of our customers, we process and retain Personal Information as necessary to provide our services to our customers, or as required or permitted under applicable law.
Onward Transfers
Our Privacy Notice describes the types of third parties that we may disclose your Personal information to, and the purposes of such disclosures. If we disclose your Personal Information to a third party acting as a data controller or as an agent, we will comply with, and protect the Personal Information as provided in, the Accountability for Onward Transfer Principle. We remain responsible for the processing of Personal Information received under the Frameworks and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Your Choice and Rights
If we intend to use your Personal Information for a purpose that is materially different from the purposes listed in this policy or our Privacy Notice, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.
You may access your personal data, update your preferences, or ask us to remove your information from our systems as well as your associated data. You may submit a request to exercise your rights available under applicable law or express your concern about the use of your information at any time. To do so, please contact us via the email address or phone number provided below in the Contact Us section. Additionally, you may choose not to provide information to us through our Services. However, if you do not provide information, you may not be able to benefit from the Services as the information may be necessary to provide you with the Services or we may be legally required to collect it in the context of the Services. Please note that if you cease using our Services or we terminate your access to the Services in accordance with your Customer Agreement, you may no longer be able to access or update your information.
Recourse and Enforcement
Centered Solutions participation in EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU and UK individuals and Swiss individuals, makes Centered Solutions subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Dispute Resolution
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and to the rights of EU and UK individuals and Swiss individuals, Centered Solutions commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and to the rights of EU and UK individuals and Swiss individuals to VeraSafe, an alternative dispute resolution provider based in the United States, the European Union, United Kingdom, and/or Swiss. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.verasafe.com/public-resources/dispute-resolution/submit-dispute/ for more information or to file a complaint. The services of Verisafe are provided at no cost to you.
If your Data Privacy complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Data Privacy Framework ANNEX 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction
Updates/Changes to Data Privacy Framework Principles
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and to the rights of EU and UK individuals and Swiss individuals, Centered Solutions commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss ICO with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and to the rights of EU and UK individuals and Swiss individuals in the context of the employment relationship.
Centered Solutions, LLC. agrees to periodically review and verify its compliance with the Data Privacy Framework Principles, and to remedy any issues arising out of failure to comply with the Data Privacy Framework Principles. Centered Solutions acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Data Privacy Framework participants, https://www.dataprivacyframework.gov/s/participant-search
Contact Us
If you have questions, concerns, or complaints about this Data Privacy Framework Notice or our privacy practices, please contact us.
Centered Solutions, L.L.C.
175 1st Street South, Unit 704
St. Petersburg, FL 33701
privacy@centeredsolutions.com
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